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HMRC internal manual

Stamp Taxes on Shares Manual

Exemptions and reliefs: reliefs: Intermediary Relief - 'Bona fide dealer in chargeable securities'

An intermediary is a person who carries on a bona fide business of dealing in stock, chargeable securities or certain options. Intermediary relief is not available to someone who just buys and sells lots of securities.

Whilst one might normally expect an intermediary to engage in at least some client business (as opposed to only conducting proprietary, or ‘own account’ trading) this is not a specific requirement for conducting a bona fide dealing business. Any activity in the relevant securities that would amount to a trade for income tax purposes is likely to meet this test. However if you become aware of any activity being carried on that appears to be aimed at avoidance of stamp duty or SDRT you should seek advice, as it is possible this might raise questions about the appropriateness of the firm’s intermediary status.